The Internal Revenue Service today announced that U.S. taxpayers with maquiladora operations in Mexico will not be exposed to double taxation if they enter into a unilateral advance pricing agreement (APA) with the Large Taxpayer Division of Mexico’s Servicio de Administración Tributaria (SAT) under terms discussed in advance between the U.S. and Mexican competent authorities.
Maquiladoras typically operate in Mexico as contract manufacturers of foreign multinationals.
This announcement represents the culmination of two years of collaboration between the competent authorities to address SAT’s current inventory of approximately 700 pending unilateral APA requests in the maquiladoras industry. It is an important step forward in strengthening ties between the two governments and providing certainty in the taxation of multinationals.
Courtesy of IRS
For more information contact Neikirk, Mahoney and Smith at 502-896-2999
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